CFPB Seeks Information on Financial Products Marketed to Students
February 7, 2013
The Consumer Financial Protection Bureau (CFPB) has published a request for information on financial products, such as bank accounts or debit cards, which carry an explicit or implicit endorsement by an institution of higher education. This covers both financial services and products offered by third parties in connection with credit balance disbursement, as well as affinity programs which add debit card functionality to student ID cards or market bank accounts to students.
After citing past scrutiny regarding preferred lender lists and affinity credit cards, which ultimately led to legislation, the notice goes on to couch this information request in a more positive light:
However, institutions of higher education may be uniquely positioned to create a beneficial environment for students in the selection of financial products and services. The Bureau is interested in better understanding the types of campus affinity products being offered, how institutions of higher education are defining these relationships, and the experience of students using these products. The Bureau seeks information on how partnerships between institutions of higher education (including their affiliated entities) and financial institutions might be structured to promote positive financial decision-making among young consumers.
The CFPB request poses 25 questions under the heading "Products marketed through campus affinity relationships," and another 18 addressing "other financial products marketed to students." A number of the questions concerning affinity relationships seek to better understand the nature of the marketplace and how agreements between institutions and financial service providers are structured.
In December, NACUBO provided guidance to its members on best practices for safeguarding student finances.
Members are encouraged to respond to the CFPB to help the agency understand how these relationships are structured and the reasons that institutions enter into them. NACUBO is working on its response and would appreciate hearing your thoughts and experiences.
Vice President, Regulatory Affairs
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